MANAGING CONFLICTS OF INTEREST. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: • The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. • Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. • If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the materia...
MANAGING CONFLICTS OF INTEREST. As part of its efforts to manage conflicts of interest, T1/HCI management has undertaken the following measures, which include but not limited to:
MANAGING CONFLICTS OF INTEREST. We may act for clients which may compete with or, more rarely, may even be involved in business with you. Naturally, we will continue to assist those clients or new clients in projects that are not substantially related to work we are engaged to perform for you. We will not disclose or use any confidential information you may disclose to us in the course of our working for you except where required in the course of our acting for you.
MANAGING CONFLICTS OF INTEREST contractors and people who provide services to the group
6.1 Anyone seeking information in relation to a procurement, or participating in a procurement, or otherwise engaging with the clinical commissioning group in relation to the potential provision of services or facilities to the group, will be required to make a declaration of any relevant conflict / potential conflict of interest.
6.2 Anyone contracted to provide services or facilities directly to the parties of this agreement will be subject to the same provisions of this constitution in relation to managing conflicts of interests. This requirement will be set out in the contract for their services.
MANAGING CONFLICTS OF INTEREST. (a) The Expert agrees to abide by the DRS Conflict of Interest Policy (attached).
(b) The Expert is required to declare any conflict of interest promptly when assigned a Dispute to determine by the DNC. In the event of a conflict of interest being notified, the DNC will reassign the Dispute to the next expert on the list. The next available Dispute will then be assigned to the Expert.
(c) No fee will be payable to the Expert for any work undertaken in respect of an assigned Dispute prior to identifying any conflict of interest.
MANAGING CONFLICTS OF INTEREST. (a) The Mediator agrees to abide by the DRS Conflict of Interest Policy (attached).
(b) The Mediator is required to declare any conflict of interest promptly when assigned a Dispute to mediate by the DNC. In the event of a conflict of interest being notified, the DNC will reassign the Dispute to the next mediator on the list. The next available mediation will then be assigned to the Mediator.
(c) No fee will be payable to the Mediator for any work undertaken in respect of an assigned Dispute prior to identifying any conflict of interest.
MANAGING CONFLICTS OF INTEREST general
5.1 Individual members of the group, the governing body, committees or sub-committees, the committees or sub-committees of its governing body and employees will comply with the arrangements determined by the group for managing conflicts or potential conflicts of interest.
5.2 The Chair of the Joint Coordinating Commissioning Group (JCCG) will ensure that for every interest declared, either in writing or by oral declaration, arrangements are in place to manage the conflict of interests or potential conflict of interests, to ensure the integrity of the group’s decision making processes.
5.3 Arrangements for the management of conflicts of interest include the following:
(i) when an individual should withdraw from a specified activity, on a temporary or permanent basis;
(ii) monitoring of the specified activity undertaken by the individual, either by a line manager, colleague or other designated individual.
5.4 Where an interest has been declared, either in writing or by oral declaration, the declarer will ensure that before participating in any activity connected with the group’s exercise of its commissioning functions, they have received confirmation of the arrangements to manage the conflict of interest or potential conflict of interest from the Chair of the JCCG.
5.5 Where an individual member, employee or person providing services to the group is aware of an interest which:
(i) has not been declared, either in the register or orally, they will declare this at the start of the meeting;
(ii) has previously been declared, in relation to the scheduled or likely business of the meeting, the individual concerned will bring this to the attention of the chair of the meeting, together with details of arrangements which have been confirmed for the management of the conflict of interests or potential conflict of interests.
5.6 The chair of the meeting will then determine how this should be managed and inform the member of their decision. Where no arrangements have been confirmed, the chair of the meeting may require the individual to withdraw from the meeting or part of it. The individual will then comply with these arrangements, which must be recorded in the minutes of the meeting.
5.7 Where the chair of any meeting of the group, including committees, sub-committees, or the governing body and the governing body’s committees and sub-committees, has a personal interest, previously declared or otherwise, in relation to the scheduled or likely business of the m...
MANAGING CONFLICTS OF INTEREST. 17.1 The CSU recognises that there may be occasions when two or more organisations may wish to receive services from CSU notwithstanding an actual or apparent conflict of interests.
17.2 In such cases the CSU will exercise considerable caution when providing services where there are competing interests for different Clients, and at all times will act in accordance with the CSU’s stated Conflicts of Interest Policy (available upon request).
17.3 In all cases the CSU will obtain Clients confirmation in writing that they are content for the CSU to provide such services, and to follow the principles and ‘Safeguards’ highlighted below:
MANAGING CONFLICTS OF INTEREST. 25.1 The Parties shall comply with the agreed principles for identifying and managing conflicts of interest via adherence to their own policies ensuring they meet the NHS England Managing Conflicts of Interest Statutory Guidance.
25.2 Where a dispute between the parties occurs this shall be subject to Clause 26 of the Agreement.
MANAGING CONFLICTS OF INTEREST. 4.1 The Company has set up internal policies and has an in-house Compliance Department that are responsible for identifying and managing potential conflicts of interests. The above will also update the relevant internal procedures and ensure compliance with such procedures.
4.2 The Company maintains and operates effective organizational and administrative procedures to manage the identified conflicts of interest. The Company also undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate.
4.3 In general, the procedures and controls that the Company follows regarding conflicts of interest include the following measures:
(a) Effective procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients;
(b) The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company; (c) The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities;
